SAFRA Gamification Platform, User Agreement

1. Acceptance of this User Agreement

This User Agreement (“User Agreement”) governs access to and use of the SAFRA Gamification Platform (the “Platform”), operated by the Operator (“Operator”) on behalf of the SAFRA National Service Association (“SAFRA”).

The Platform forms part of SAFRA’s online services. This User Agreement is to be read together with, and supplements, the SAFRA Website Terms of Use and the SAFRA Privacy Policy (together, the “SAFRA Policies”), as well as the SAFRA Gamification Platform Code of Conduct (the “Code of Conduct”), which is incorporated into this User Agreement by reference.

By registering for, accessing, or using the Platform, you agree to be bound by this User Agreement, the SAFRA Policies, and the Code of Conduct. If you do not agree, you must not register for or use the Platform.

If you are below the age of 16.5 years, you may use the Platform only with the involvement of a parent or legal guardian. You represent and warrant that your parent or legal guardian has reviewed and agreed to this User Agreement on your behalf and has authorised your use of the Platform.

 

2. Relationship with the SAFRA Policies and order of precedence

This User Agreement does not stand alone. It applies in addition to the SAFRA Policies and must be read consistently with them.

  • In the event of any inconsistency between this User Agreement and the SAFRA Website Terms of Use in relation to the Platform, this User Agreement shall prevail to the extent of the inconsistency, and only in respect of the Platform.
  • All matters relating to the collection, use, disclosure, and protection of personal data are governed by the SAFRA Privacy Policy, which prevails over this User Agreement in respect of personal data.
  • Where this User Agreement is silent on a matter, the SAFRA Website Terms of Use apply.

Capitalised terms not defined in this User Agreement have the meaning given to them in the SAFRA Policies.

 

3. Eligibility

The Platform is available to Singapore citizens and permanent residents located in Singapore.

SAFRA employees (permanent or temporary) and employees of the Operator are allowed to participate in the Games but will not be eligible for competitions and/or to win prizes.

SAFRA and the Operator reserve the right to restrict, suspend, or terminate access to the Platform at any time where eligibility requirements are not met or where misuse is suspected, consistent with SAFRA’s rights under the SAFRA Website Terms of Use.
 

4. Registration and authentication

To access certain Platform features, you must register with a valid email address. Authentication is performed through a One-Time Password (“OTP”) sent to the email address you provide.

As with any SAFRA account, you are responsible for maintaining the confidentiality of your account and for all activities that occur under it. In particular, you are responsible for:

  • maintaining control of your email account;
  • ensuring that the email address provided remains valid and accessible; and
  • promptly notifying the Operator of any unauthorised use of your account.

The Operator may suspend or terminate accounts where false, invalid, temporary, disposable, or inaccessible email addresses are used.

 

5. Personal data

The Platform is one of SAFRA’s “Platforms” as defined in the SAFRA Privacy Policy. The collection, use, disclosure, processing, and protection of your personal data in connection with the Platform are governed by the SAFRA Privacy Policy, in accordance with the Personal Data Protection Act 2012 (“PDPA”). By accessing the Platform, you consent to SAFRA’s collection of your personal data for purposes such as participating in the game, campaign or activity, user authentication and agree that SAFRA may, for this purpose(s), collect, use and/or disclose your personal data in accordance with the terms and conditions in this User Agreement and SAFRA Privacy Policy.

For transparency, personal data and records processed for the operation of the Platform may include:

  • email address and authentication records;
  • gameplay activity, quiz participation, scores, and rankings;
  • campaign participation records, points earned and redeemed, and redemption history; and
  • technical and security logs reasonably required to operate and protect the Platform.

Such data is processed for purposes including user authentication; administration of campaigns and competitions; points calculation and reward fulfilment; fraud prevention and platform security; investigating misuse or breaches; and generating usage statistics and reports. These purposes are consistent with, and form part of, the purposes set out in the SAFRA Privacy Policy.

Personal data may be hosted and processed on systems located in Singapore. Any transfer or hosting of personal data outside Singapore will be carried out in accordance with the SAFRA Privacy Policy and the PDPA. Questions, access or correction requests, and withdrawals of consent relating to personal data may be directed to SAFRA’s Data Protection Officer at dpo@safra.sg.

 

6. Campaigns, games, and activities

The Platform may include games, quizzes, educational content, campaigns, competitions, challenges, leaderboards, and other activities.

SAFRA and the Operator may add, modify, suspend, or discontinue any game, campaign, activity, or feature at any time without prior notice. Campaign rules, reward criteria, points allocation mechanisms, eligibility, and redemption requirements may differ between campaigns. Additional campaign-specific rules may apply and shall form part of this User Agreement.

 The details on campaign-specific rules shall be provided on the Platform at each game, campaign or activity level. 

 

7. Points and rewards

You may earn points through participation in games, quizzes, campaigns, competitions, or other activities. Points:

  • have no cash value and cannot be exchanged for money;
  • cannot be sold, transferred, assigned, or gifted;
  • may only be used within the campaign for which they were awarded; and
  • expire upon the completion or expiry of the relevant campaign unless otherwise stated.

The Operator reserves the right to determine, verify, adjust, withhold, remove, or invalidate points where errors, abuse, fraud, technical issues, or breaches of this User Agreement or the Code of Conduct are identified.

8. Rewards redemption

Rewards may include vouchers, merchandise, event tickets, experiences, or other items as determined by SAFRA or the Operator. Reward availability is subject to stock, campaign conditions, verification requirements, and other applicable criteria. Certain rewards may require collection at designated SAFRA locations or other collection points.

SAFRA and the Operator reserve the right to substitute rewards with alternatives of similar nature or value, amend redemption requirements, modify reward inventories, or withdraw rewards without prior notice. Unless expressly stated otherwise, rewards are non-transferable and non-exchangeable.

 

9. Leaderboards and competitions

The Platform may display public campaign leaderboards showing masked derivatives of usernames (a***k@g***m), rankings, scores, achievements, or other competition-related information. The publication of such information is consistent with the purposes set out in the SAFRA Privacy Policy.

Participation in campaigns may be based on skill, achievement, chance, or a combination thereof, as determined by the applicable campaign rules. The Operator’s determination of scores, rankings, winners, rewards, eligibility, and campaign outcomes shall be final and binding.

 

10. Fair use and prohibited conduct

You must use the Platform fairly and lawfully, and in accordance with the Code of Conduct. Without limiting the SAFRA Website Terms of Use (including its restrictions on data mining, robots, and similar data-gathering or extraction tools), you must not:

  • create multiple accounts to gain an unfair advantage;
  • use bots, scripts, automation tools, or artificial means to participate;
  • exploit software bugs, vulnerabilities, or unintended behaviour;
  • attempt to manipulate scores, rankings, points, rewards, or campaign outcomes;
  • interfere with the operation, security, or availability of the Platform;
  • reverse engineer, decompile, or attempt to gain unauthorised access to Platform systems; or
  • engage in fraudulent, deceptive, abusive, or unlawful conduct.

The Operator may investigate suspected violations and take any action it considers appropriate, including the enforcement actions set out in the Code of Conduct.

 

11. Suspension and termination

Consistent with SAFRA’s right to refuse service and terminate accounts under the SAFRA Website Terms of Use, the Operator may suspend, restrict, or terminate any account immediately and without prior notice where:

  • a breach of this User Agreement or the Code of Conduct is suspected or confirmed;
  • fraudulent or abusive conduct is suspected;
  • security concerns arise; or
  • compliance, legal, operational, or business reasons require such action.

Suspended or terminated users may lose access to points, rewards, campaign participation records, and other Platform benefits.

 

12. Intellectual property

All Platform content, including software, graphics, games, quizzes, text, artwork, branding, designs, logos, and educational materials, remains the property of SAFRA, the Operator, their licensors, or respective rights holders. Your use of such content is subject to the copyright, trademark, and licence provisions of the SAFRA Website Terms of Use. No rights are granted except the limited right to use the Platform for personal, non-commercial purposes in accordance with this User Agreement.

 

13. Availability of service

The Platform is provided on an “as is” and “as available” basis, consistent with the warranty disclaimer in the SAFRA Website Terms of Use. Neither SAFRA nor the Operator guarantees that the Platform will operate uninterrupted or error-free, that scores, rankings, points, or rewards will be accurately recorded at all times, or that defects will be corrected within any specified timeframe. Maintenance, upgrades, technical issues, security incidents, or circumstances beyond reasonable control may affect availability.

 

14. Limitation of liability

To the maximum extent permitted by Singapore law, and consistent with the limitation of liability in the SAFRA Website Terms of Use, SAFRA, the Operator, and their respective officers, employees, contractors, agents, and service providers shall not be liable for any indirect, incidental, special, punitive, or consequential loss or damage, or any loss of profits, data, or business, arising from or relating to:

  • use of, or inability to use, the Platform;
  • delays, interruptions, outages, or service failures;
  • errors in scoring, rankings, points calculations, or reward allocations;
  • loss of points, rewards, campaign participation records, or account access;
  • unauthorised access to user accounts; or
  • technical faults, software defects, or third-party service failures.

Nothing in this User Agreement excludes or limits any liability that cannot be excluded or limited under applicable law.

 

15. Third-party services

The Platform may rely on third-party hosting providers, cloud infrastructure, email delivery services, analytics tools, software components, and other supporting services. Consistent with the SAFRA Website Terms of Use, neither SAFRA nor the Operator is responsible for the acts, omissions, availability, or performance of third-party service providers.

 

16. Account deletion and data retention

You may request deletion of your account through the Platform’s account-management functions where available, or by contacting SAFRA. Upon deletion, access to your account, campaign history, points, rewards, rankings, and related records may be permanently lost. Personal data will be retained and deleted in accordance with the retention provisions of the SAFRA Privacy Policy, and may be retained where required for security, audit, fraud-prevention, legal, regulatory, or operational purposes.

 

17. Amendments

SAFRA and the Operator may amend this User Agreement at any time. The updated User Agreement will be published on the Platform and take effect upon publication unless otherwise stated. Consistent with the SAFRA Website Terms of Use, your continued use of the Platform after publication constitutes acceptance of the amended User Agreement, whether or not actually reviewed by you.

 

18. Governing law and dispute resolution

This User Agreement is governed by and construed in accordance with the laws of the Republic of Singapore.

Any dispute arising out of or in connection with this User Agreement or the use of the Platform shall be resolved in accordance with the dispute resolution provisions of the SAFRA Website Terms of Use (which provide for arbitration administered by the Singapore International Arbitration Centre, save for SAFRA’s right to seek injunctive or other relief in the Singapore courts in respect of intellectual property). This clause ensures that the resolution of disputes under this User Agreement is consistent with, and does not contradict, the SAFRA Website Terms of Use.

 

19. General

If any provision of this User Agreement is found to be invalid or unenforceable, it shall be severed without affecting the remaining provisions. The general provisions of the SAFRA Website Terms of Use (including those relating to electronic communications, severability, and waiver) apply to your use of the Platform.

 

20. Contact

Questions about this User Agreement or the Platform may be directed to the Operator through the contact details published on the Platform. Questions or requests relating to personal data should be directed to SAFRA’s Data Protection Officer at dpo@safra.sg.